EU Labelling Requirements for Cosmetics

It’s not a very sexy title, we know, but labelling on cosmetics is important – it tells us, the consumer, things like what the product is, what’s in the product, how much there is, when to use it by and who made it. Anyone working in makeup should understand what the labels mean.

Labelling Requirements

Product labelling in the EU is regulated by law under the EU Cosmetics Regulations (1223/2009).

All cosmetic and personal care products must have a label, which is indelible and easy to read, and included the following information:

List of ingredients

Name and address of manufacturer or supplier

Date of minimum durability (“best before date”) or a “Period After Opening” (PAO)

Warning statements and precautionary advice

Batch number or lot code

Product function (when appropriate if use is not obvious)

The amount of contents (weight or volume)

Ingredients

The outer packaging of a MAC blush showing the ingredients in the product, as well as the name and address of who made it. Talc is the largest component here, as it is shown first on the list.

Ingredients have to be listed on any outer packaging or, if no outer packaging, on the main container.

There must be the title “Ingredients” followed by all the ingredients contained in the product, in descending order of concentration.

The ingredients have to follow a standard with regard to terminology so there is consistency between different brands, and this is set in the International Nomenclature for Cosmetics (INCI). This means that wherever you buy the product, the ingredients list is using the same terms, keeping the ingredients used easier to identify;

The term “parfum” means perfume, which can consist of many ingredients. These do not have to be listed individually, with the exception of certain ingredients which must be shown on the label;

The term “aroma” means flavour and, like parfum, the raw materials in the aroma do not need to be listed, with a few exceptions;

Ingredients are shown in descending order of weight. For ingredients that are in concentrations of less than 1%, they can be listed in any order after all other ingredients;

Colouring agents are shown by “Cl” followed by its number and can be listed in any order after all other ingredients;

For a range of coloured products that come in different shades, the symbol “+/-” or words “may contain” before the list of colours means that not all the colours listed are necessarily used in every shade;

Nano ingredients must have “(nano)” after it.

Name and Address

The name and address of the manufacturer or supplier is required on both the primary container and any outer packaging.

If the product is made outside of the European Economic Area (EEA), the country of origin must also be shown on the label.

Durability

Cosmetic products must indicate when they are best used by or how long they should be kept. This is either via a “Best Before Date” or a “Period After Opening” (PAO) symbol. A PAO symbol is far more common, as most cosmetics are formulated to have a long shelf life.

Best Before Date

Any cosmetic product that has a lifespan of less than 30 months from the date of manufacture must have a “best before the end of” date on the packaging.

This is shown by the words “best before” followed by the date (month/year) when the product either ceases to fulfil its intended function, or no longer meets safety requirements as per the regulations.

“Best before” can be abbreviated to “Exp”, and “Best Before End” to “BBE”. The “egg timer” symbol may also be used.

Any special precautions to be observed e.g. storage conditions, in order to maintain the product as required by the regulations must also be shown on the packaging.

Period After Opening

For products with a lifespan longer than 30 months, they must have a “Period After Opening” time.

This means once a product has been opened by the consumer for the first time, it has a shelf life of so many months under normal conditions of use.

It is shown on cosmetics as an open pot with a number in it and an “M” – this shows the number of months that the product is safe to use once it has been opened.

Warning Statements and Precautionary Advice

Not all products have this on them. It is for any special information like how a product must be properly used or disposed of safely. It also includes warnings about ingredients, preservatives or UV filters, or how not to use a product.

Examples of precautionary advice: “Avoid eye area”; “Do not use to dye eyelashes”.

Batch Number or Lot Codes

This is a code that enables the manufacturer or supplier to identify when and where the product was made.

Product Function

This is only required on a label if the function of the product is unclear from the presentation and design. For example, the function of lipstick is clear; however, a depilatory cream could not be labelled just as “cream” – it would have to state that it was for hair removal.

Net Contents or Weight

The amount of product at the time of packaging must be given on the label, and can be shown as a weight or volume.

For the EU, the net contents must be given in metric (grams, millilitres), though some may also list the weight for other markets e.g. the USA (so the weight will also be listed in ‘US OZ’).

The “e” symbol (which means ‘estimated’) is a guarantee that the product has been filled in accordance with the average system of measures used in the EU.

The term “Net Wt.” may also be seen by the weight/volume.

Some products are exempt from this requirement, including free items, sachets for single application and anything less than 5g or 5ml.

Further Information

Where there is not enough space on a product to include the ingredients list or warnings and instructions for safe use, the manufacturer will include that information somewhere else in the packaging – for example, on a leaflet.

The “Hand & Book” symbol shows that information is included elsewhere in the packaging.

Other Information Given on a Label

A product’s label can provide other information, which is down to the manufacturer rather than it being a legal requirement.

Organic or Natural

There is no legal definition for organic cosmetic products in the EU. A company could label a product “organic” even if that product only had 1% organically-produced ingredients.

Other similar terms used on labels are “natural” and “green“, for example. Again, no legislation is in place for these terms – they are used by manufacturers to simply make the consumer think they are buying something pure, better or safer.

To find certified organic products, there are five European certification bodies that have developed the Cosmetics Organic Standard (COSMOS) to try and harmonise organic standards across the globe. They have high standards, and to achieve COSMOS certification for a product, that product has to meet a strict set of criteria. It ensures that the product contains guaranteed organic ingredients, and is not just label trickery.

COSMOS organisations that certify cosmetics as organic

Marketing Terms

Some labels have marketing terms on them, which imply that a product is not going to cause a reaction/irritation or have some sort of benefit to the user.

Terms such as “hypoallergenic“, “dermatologist tested”, “allergy tested” or “non-irritating” have no legally-defined meaning and are used to make consumers think the product will not cause irritation. However, no proof of this is needed from the company – anyone can put these terms on a label.

Non-Animal Testing

The “Leaping Bunny”

To find products that really are cruelty-free, look for the “leaping bunny” symbol on cosmetics and household products. These products have been thoroughly assessed by Cruelty Free International and are certified as genuinely cruelty-free.

Some companies may take liberties on labels and can use word trickery to make the consumer think that their non-animal testing policy is more than it actually is. Example: “We do not test on animals” may mean that the company itself doesn’t test on animals, but may contract another company to animal test on its behalf.

What the Product Doesn’t Contain

Manufacturers may state on a label what is not in their product.

It’s often things like parabens, preservatives, synthetic fragrance or colourants – those ingredients that some consumers do not want in their products, or find irritating to their skin.

Recycling Advice

The “Green Dot” is a trade mark that shows the company has membership of a recycling and recovery scheme to deal responsibly with the packaging waste of their products.

All companies in Europe and the UK have a legal obligation to recycle and recover packaging waste. Companies often pay a specialist company to do the work on their behalf.

In the UK, there are a number of competing recovery and recycling schemes, so this logo is not used; however, you will still the green dot on packaging in the UK for products that are also sold in other European countries.

So, that’s a look at EU labelling requirements for cosmetics. Some aspects of labelling are legislated and have to follow the law in order to be compliant. Other aspects of a label are simply down to the manufacturer – and can be informative, or misleading. It is a case of caveat emptor – let the buyer beware! The full legislation can be found in the links below.

I live in the UK and only speak English.i ordered some Vichy sunscreen online – the product shot online was of a bottle with English writing on it – yet I received Greek stock – have no idea what is written on the label, how to apply it etc – the company will not let me return or replace it with English stock – what is the law/regulation with this please? (Edited by H&MUA: removed company name)

Hi Lisa, as far as we understand, cosmetics sold in the UK must have English included on labels to fulfil the legislation i.e. customer safety. As you said, you have no idea what the ingredients are, how to use, any safety advice etc. Please get in touch with CTPA (Cosmetic Toiletry & Perfumery Association) based in London: Tel: 020 7491 8891 | E-mail: info@ctpa.org.uk. They will know the current legislation and be able to advise you accordingly. All the best.

Hi Ting – All cosmetic products supplied in the EU/UK, whether for consumer or professional use, must comply with European Cosmetics Regulation 1223/2009. It also requires safety assessments on the products. We’re not quite sure what you mean by “not fully tested” – as cosmetics have to be tested thoroughly 🙂

This is all very thorough but we still need to go further. My daughter is peanut and nut allergic. All food is labelled with allergens in bold or a warning. There does not seem to be the same duty of care within the beauty industry. The facial scrub I bought yesterday listed jurglans regia as an ingredient. I did Latin at university but still had to google what that is. Why did it not say it was walnut even in brackets?? I just feel food labelling has become almost too thorough. The beauty industry needs to think about allergies and maybe start having warning labels on as well.